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Conclusions Based on standard EPA methods, air quality impacts are far below all EPA National Ambient Air Quality Standards Risks are below de minimis levels and far below reporting levels based on strict California guidelines Noise levels are far below County requirements Odor issues are not significant 3

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Conclusions (Cont.) Opponents of the gas station are basing opposition on the premise that EPA air quality standards are not sufficiently protective Regulatory and land use decisions need to be based on objective facts and standards Absent alternative, defined air quality standards at the County level, there is no other objective basis to evaluate air quality impacts other than consideration of published national standards and accepted guidelines for risk assessment 4

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Conclusions (Cont.) The impacts from the Costco gas station are low in 2013 when the station opens, and will be lower over time as enhanced motor vehicles evaporative and tailpipe controls are further incorporated into the fleet Costco Wheaton gas station is relatively large in terms of sales but not large in terms of emissions relative to trend lines (see attached figures) 5

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12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller Stations in 1980s & 1990s and Will Continue to Drop 6 This graph was based on the best estimate of when a particular emissions control strategies would be fully enacted, usually after 10 years of having the control technology first promulgated. We took the average of the original and controlled emission rate for time periods in between the 10 year block just to keep the graphs smooth and to show that technologies were being phased in over time, which is consistent with EPA methods.

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12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller Stations in 1980s & 1990s and Will Continue to Drop 7 Not Unprecedented: VOC emissions gasoline marketing Costco in 2013 Comparable to 1.5 M gal/year in 1987 and 3 M gal/year in 1998

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12 M Gallons / year Station with Vent Control at 99.7% in 2013 Similar to Smaller Stations in 1980s & 1990s and Will Continue to Drop 8 Not Unprecedented: VOC emissions gasoline marketing Costco in 2020 Comparable to 1.5 M gal/year in 1997 and 3 M gal/year in 2005

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Overview Submitted initial environmental report: July 2012 September 2012 met with Kensington Heights consultant: Dr. Henry Cole Developed modified protocol including comments from Dr. Cole Final report shows modeling results for Costco sources based on consensus approach Interpretations may differ, but basis for concentrations for modeled incremental Costco sources are drawn from a common protocol 13

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Benefit to Reviewers on Achieving Consensus of Modeling Methods Complex modeling treatments are based on consensus methods to address incremental Costco sources County staff and hearing examiner can focus on interpretation of results 14

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Not Implying Consensus on All Issues Differing interpretations of fine particulates can be supported from common modeling results Dr. Cole requested broader scope of modeling other operations at the mall and beyond - - (but conservatively addressed through background) - - alternative background treatments can be considered based on common modeling results 15

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Summary of Conservative Assumptions Maximum peak traffic counts were used for all averaging times (very conservative) - - overstates (applies to Ring Road and Mall) Assumed 90 percent of cars entering mall park at Costco lots and used peak traffic into mall for all analysis of parking lot emissions (applies to traffic going South at #16 and #20) Used EPA conservative background method of assuming highest regional value for each averaging time occurs all the time (and corresponds with every peak modeled value) Double counted some sources when modeling roadways and using conservative background contribution 18

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Background Treatment 27 Conservatively used highest measured for all modeled locations. Overstates background relative to what would be expected in January 2013, Parks & Planning staff requested that PM 2.5 annual background be updated to more accurately reflect current conditions and to maintain compatibility with Washington Council of Governments recommendation of 10.8 µg/m 3. By ~ 2014 when station is open, trend suggests that background will be < 10.8 µg/m 3.

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Treatment of Background Concentrations is a Standard Procedure in Modeling for EPA or MDE Defined Term in EPA Guideline on Air Quality Modeling: as including: (1) natural, (2) nearby sources other than the one(s) currently under consideration, and (3) unidentified sources. By way of clarification, EPA specifies that all sources expected to cause a significant concentration gradient in the vicinity of the source or sources under consideration for emission limit(s) should be explicitly modeled Per above, Costco has modeled all sources with potential for causing significant gradients at the Costco gas station source: Costco gas station operations (fueling, spillage, delivery) Ring Road Costco warehouse Major nearby roadways (University, Viers Mill, Georgia Ave) Costco parking lot and parking garage 28

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Actual Trend in PM 2.5 Measured Concentrations (Background) 29 This figure was produced from using the raw annual average daily data from Rockville, Beltville, and Arlington accessed from: /ad_data_daily.html. /ad_data_daily.html This data included all monitoring locations at each site where annual averages were computed and then a 3-year running averages was used to simulate the NAAQS. For example, the 3-year running averages for 2010 is the annual average of 2008, 2009 and Supplemental Report Figure 4.2: Trends in PM2.5 Concentrations Based on Rockville, Beltsville, and Arlington Monitoring Sites (three-year running averages from 2005 through 2012)

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Importance of Dose: National Ambient Air Quality Standards Based on Defining Acceptable Dose Air pollution does not create adverse health affects at all concentrations EPA defines acceptable concentrations (dose) with a reasonable margin of safety to protect the most sensitive members of the population Asthmatics and children are specifically identified in the Clean Air Act sensitive subpopulations to be protected The Costco Wheaton gas station, modeled using standard EPA methods, is well below all EPA standards 34

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Detailed Concentration Plots and Other Detailed Tables Available in Report and on Slides as Needed Presentation presents overview for key locations: closest residence, Kenmont Swim and Tennis facility, and the Stephen Knolls School; detailed concentration aerial overlay plots are available in project reports. Overall modeled concentrations are shown in presentation, but contributions from each source is available as needed to support discussion 35

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Summary Table Showing Modeled Rural Concentrations at Pool and School Compared to Average Background Standards (µg/m 3 ) Based on Conservative Rural Land Use (overstates close-in locations) 36 Locations CO 1-Hour Maximum CO 8-Hour Maximum NO 2 1-Hour Maximum NO 2 Annual Average PM 2.5 Max 24- hr PM 2.5 Annual Average (10.8 Background) Pool12,6463, School13,4803, Average Background 1,4881, * Total for Pool 14,1344, Total for School 14,9684, Standard40,00010, *28 was changed to 6.8 for supplemental report based on further analysis of background data

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Odors Supplemental report: 2.6% time closest homes to SSW and 4.9% SSE are upper bound estimates Based on Sterling (without vent control at 99.7%)- - about half of fueling emissions expected in total in Wheaton with the planned controls. Does not account for near-end of incompatibility period between on-board canister controls for vehicles and venting from vehicles to underground tank – Full Transition in MD 2-3 years When rely exclusively with on-board canisters (expected by within several years) there will be 4x reduction from fueling emissions as compared to the Sterling odor study. 41

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Odors (Cont.) With vent controls (99.7%) at Wheaton station and reliance on on- board canisters in the future, odors expected to be within the Ring Road. 42

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Risk Assessment Most Useful as Relative Risk Comparison - - Not an Indication of Absolute Risk CARB 10 in a million notification level is a risk management tool For relative comparison, EPA modeling applicable for Montgomery County shows ~ 65 in a million as background risk for specific set of pollutants modeled (EPA monitoring shows in a million for this area) Based on urban modeling highest relative risks from Costco gas station operations is < 1 in a million 45

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Conservative Occupancy Calculation 46 Percent in School Average life expectancy Days per year hoursyears # of hours over 18 years % Occupancy , hrs in 70 years613,200 Percent at Pool Average life expectancy Days per year hoursyears # of hours over 18 years % Occupancy , hrs in 70 yrs613,200

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Ultrafine Particulates Maximum annual average fine particulates at closest residence is µg/m 3. If MOVES was available maximum may increase to ~ 0.01 µg/m 3. New standard is 12 µg/m 3 ; background is 10.8 in 2013, and less by 2014 and beyond EPA and expert panel (CASAC) reviewed literature and conclusion: new standard protective of most sensitive with adequate margin of safety EPA defines insignificant contributions to fine particulates for this region as 0.3 µg/m 3, i.e. Costcos maximum impact is 30 lower than EPAs defined level for insignificant contributions if maximum Costco impacts are doubled There is no objective or rational basis for concern based on ultrafine particulates contributions from the Costco gas station 51

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Diesel Emissions From 4 Costco Clean Diesel Delivery Trucks / Day Do Not Present a Significant Source Four clean diesel trucks per day to gas station The emissions of particulate mass in NTDE (clean diesels) are substantially lower (less than 1%) than those emitted from 1988 engines. 1 In fact, the nanoparticle number concentration emissions contained in NTDE are well below typical urban ambient air concentrations, and amount to a 10,000-fold reduction when compared against older diesel engines not equipped with DPFs (Barone et al., 2010). 1 Most importantly, NTDE is virtually free of the elemental carbon particles found in TDE 1 Diesel emissions from the Costco gas station are not significant 1 R.O. McClellan et al. / Regulatory Toxicology and Pharmacology 63 (2012) 225–258 52

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Highest Levels of Ultrafine Particles and Most Toxic are Not Direct Emissions But Photochemically Produced in Atmosphere on a Regional Basis 54 Direct counts during Rush hour period Counts off-peak but after Photochemical Reactions in atmosphere Varma, V. et. al., Redox Activity of Urban Qauasi-Ultrafine Particles from Primary and Secondary Sources, Atmospheric Environment, 43 (2009)

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Ultrafine Particulates & Fast Food Restaurants: Common Commercial Source >> Costco Gas Station Fast-food restaurants are common commercial facilities permitted in Montgomery County Restaurants, especially fast food and grill outlets that conduct a lot of frying, are also thought to contribute to UFP concentrations. For example, measurements from the California Childrens Health Study reported high UFP levels (similar to those near major freeways) at a monitoring site next to a fast- food restaurant (38) while a study of UFP concentrations in Manchester, England suggested high restaurant density as a predictor of elevated UFP concentrations. A Land Use Regression Model for Ultrafine Particles in Vancouver, Canada », Rebecca Abernethy, B.Sc., The University of British Columbia, 2008 a thesis submitted in partial fulfillment of the requirements for the degree of master of science in the faculty of graduate studies (Occupational and Environmental Hygiene). 55

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Risks at School and Pool Are Insignificant Important omission when discussing the school and pool: dose National Ambient Air Quality Standards are developed to protect the most sensitive subpopulations with a reasonable margin of safety, and specifically children and asthmatics All standards and guidance are met with wide margins at the school and pool 56

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Long-Term Monitoring of Air Quality and Meteorology Even large industrial sources are not required to conduct the extensive air quality and meteorological monitoring proposed by opponents to the gas station Standard practice would be to use existing meteorological data for a setting such as this and to conservatively use regionally available air quality data to address background contributions Unlikely to be one gas station in the U.S. that has conducted extensive pre or post construction air quality and meteorological monitoring as requested by the opposition EPA recommends three years of air quality data to ensure a stable data set, which obviously is inconsistent with the permitting process for facilities of this nature - - reason for EPA use of regional data 57

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Modeling of All Parking Lots and Other Loading Docks (90 % cars peak hours to Costco lots: very conservative) Costco has most likely conducted the most extensive air quality modeling analysis of any gas station in the U.S.: All gas station operations including (filling of underground tanks, filling of motor vehicles, spills, queuing, ingress / egress) Ring Road Costco warehouse parking lots and loading dock All major nearby roadways and intersections (University, Viers Mill, and Georgia Avenue) The results would be substantially lower if it were feasible to model all sources of air pollution within and beyond the mall and not use the highly conservative background approach recommended by EPA (and followed here) 58

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What if Include Other Loading Docks Included and Unrealistically Assume Same Parking Rates as Costco Throughout the Mall Giant Sears Target Costco

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What if Include Other Loading Docks Included and Unrealistically Assume Same Parking Rates as Costco Throughout the Mall (Cont.)

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Alleged Terrain Complications - - No Basis in Fact to Suggest This is a Significant Issue No regulatory agency in the country would require specialized micrometeorological study or specialized modeling because of the presence of a small drop in terrain as occurs here This topic was addressed during the protocol discussion, supplemental modeling analysis was conducted as requested by the opposition, which showed terrain issues to be insignificant There is no scientific basis to allege that the presence of the hill would result in exceedances of any accepted air quality standard The allegation in fact is inconsistent with the terrain slope, the vegetation cover, the surface material at the mall, the hours of operation of the school, and all other factors considered See supplemental PowerPoint. 62

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Percent of Possible Hours That Could Even Potentially Have the Gravity Flow Conditions is Very Small Gravity flow (redirection towards residential area to the south) of emissions from Costco gas station can only occur when all of the following conditions occur: When the gas station is open When flow is from the southerly direction During nighttime conditions (1 hr sunrise) Non-overcast conditions Light wind speeds, such as 7 mph Review of 5 years of meteorological data shows that all of the above conditions occur ~ 4 percent of the time maximum potential See next slide for unlikely gravity flow impacts toward community even when all conditions are aligned (i.e. the 4 percent described above) 63

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Alleged Gravity Flow Concern is Inconsistent with Facts Terrain slopes up towards Ring Road (not down) Flow if deflected from screening wall would flow to the East, which slopes towards the North and away from the neighborhood The alleged impacts at the school are incorrect since the school is open 8:55 AM to 3:10 PM - - inconsistent with the nocturnal nature of this potential condition Most of the year there is vegetation cover along the downslope towards the community which would inhibit the formation of gravity flow conditions (actual potential less than 2 percent) 64

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School Siting Guidance (CARB and EPA) Developed by California (CARB) and EPA to guide siting of new schools when site-specific air quality studies are not available Based on hypothetical, unrealistic meteorological data (1 m/sec wind speed and nighttime restrictive dispersion all the time) Assumes 100 percent occupancy for a lifetime Does not consider prevailing flow relative to offsite locations, control equipment at the station, etc. Does not consider 99.7% vent control at Costco Wheaton Both EPA and CARB indicate that generic guidance is overruled by site-specific analysis (see next slide) 65

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School Siting Guidance Costco has conducted site-specific analysis that overrides simple screening methodology 66 CARB EPA If an LEA is considering locations that are in proximity to air pollution sources that may pose potential risks, an understanding of those potential exposures and risks is essential. Due to the many variables involved (such as those included in Exhibit 5: Factors Influencing Exposures and Potential Risks from Nearby Hazards), assessing risks from air pollution is inherently complex and should be performed by a trained environmental professional with monitoring, modeling and risk assessment expertise.

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Attempts to Link Gas Station to Major Federal Environmental Requirements (that are obviously not applicable to a gas station) EPAs Conformity Rule: applies to Federal actions and of much larger size than building a gas station (Conformity determinations are not required under this subpart for individual projects which are not FHWA/FTA projects. However, § applies to such projects if they are regionally significant - - neither of which applies to building a gas station) National Environmental Policy Act (NEPA) does not apply to building a gas station: (Not a Federal action and not of sufficient size) Prevention of Significant Deterioration (PSD) does not apply to a gas station (not a major source per PSD definition: not applicable) 67

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Changing the Definition of a Gas Station Costco is proposing to build a gas station to sell gasoline (only) to the public The emissions from the gas depot resemble emissions from a small factory.. Larry Silverman 4/4/13 Do the Clean Air Act (CAA) National Ambient Air Quality Standards (NAAQS) guarantee that the regional gasoline distribution center proposed by Costco is safe? Larry Silverman 4/4/13 68

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Reduction in Energy Consumption and Greener Environment for County Business model of Costco results in more combined trips (combined shopping and gasoline purchase) Reduced driving emissions through centralization of shopping Reduced driving for Costco members that now drive outside of Montgomery County to purchase gasoline Greater controls on Costco gas stations as compared to alternatives: Arid permeator reduces vent emissions 99.7% versus standard gas station Attendant always on duty to respond to spills and to take corrective action 69